ML20134N107
| ML20134N107 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/10/1997 |
| From: | Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 9702210204 | |
| Download: ML20134N107 (3) | |
See also: IR 05000271/1996009
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February 10,1997
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Mr. Donald A. Reid
Vice President, Operations
Vermont Yankee Nuclear Power Corporation
RR 5, Box 169
Ferry Road
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Brattleboro, VT 05301
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Subject: Inspection Report 50-271/96-09
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Dear Mr. Reid:
This refers to thu vecember 20,1996 correspondence, in response to our letter dated
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December 2,1996, regarding Vermont Yankee. This correspondence dealt with Notice of
Violation 50-271/96-09-06.
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Thank you for informing us of your corrective actions. We have reviewed this matter in
accordance with NRC Inspection Manual Pr'ocedure 92902, Maintenance and 92903,
Engineering. We concur with your assessment of the root cause being deficient
communication between Design Engineering and the Maintenance Department and within
Design Engineering. The corrective actions you have taken or planned for the violation
documented in inspection report 96-09 appear to appropriately address the identified
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surveillance test deficiency root and contributing causes. These corrective actions will be
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examined during a future inspection to assess their overall effectiveness. Although not
specifically referenced in your response, we note that your current design basis
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documentation initiative should bolster your efforts to improve the linkage between design
basis information and current operating and test procedures. We urge you and your staff to
continue this initiative.
Your cooperation with us is appreciated.
Sincerely,
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Fachard J. Conte, hief
Projects Branch 5
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Division of Reactor Projects
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9702210204 970210
ADOCK 05000271
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Mr. Donald A. Reid
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Docket No. 50-271
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cc:
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R. McCullough, Operating Experience Coordinator - Vermont Yankee
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G. Maret, Plant Manager
J. Duffy, Licensing Engineer, Vermont Yankee Nuclear Power Corporation
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J. Gilroy, Director, Vermont Public Interest Research Group, Inc.
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
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Chief, Safety Unit, Office of the Attorney General, Commonwealth of
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cc with/ copy of Licensee's Response Letter:
R. Gad, Esquire
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G. Bisbee, Esquire
T. Rapone, Massachusetts Executive Office of Public Safety
State of New Hampshire, SLO Designee
State of Vermont, SLO Designee
Commonwealth of Massachusetts, SLO Designee
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Mr. Donald A. Reid
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Distribution w/ encl:
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Region I Docket Room (with concurrences)
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PUBLIC
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
D. Screnci, PAO (2)
R. Conte, DRP
D. Beard, DRP
L. Harrison, DRS
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DOCUMENT NAME: Q:\\ BRANCH 5\\V9609.RSP
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To e e copy of this document, indicate in the box: "C" = Cop without attachment / enclosure
- E' = Copy with attschment/ enclosure
- N* = No copy
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OFFICIAL RECORD COPY
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VERMONT YANKEE
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NUCLEAR POWER CORPORATION
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Ferry Road, Brattleboro. VT 05301-7002
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ENGINEERING OFFICE
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580 MAIN STREET
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BOLTON. MA 01740
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(508) 779-6711
December 20.1996
United States Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, DC 20555
References: (a) License No. DPR-28 (Docket No. 50-271)
(b) Letter, USNRC to VYNPC. Notice of Violation - NRC Integrated Inspection
Report," NVY 96-181, dated 12/2/96
Subject: Reply to a Notice of Violation -Inspection Report '4o. 50-271/96-09
This letter is written in response to Reference (b) which documents that our activities were net
in full compliance with NRC requirements. The violation. classified as Seventy Level IV. was
identified during an NRC inspection conducted from September 16-20,1996. Our response to
the violation is provided below.
Violation
10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires written test procedures
which incorporate acceptance limits contained in applicable design documents. ANSI
N18.7-1976Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7-1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 5.2.19.3, " Test Associated with Plant Maintenance, Modifications er
Procedure Changes," requires procedures to include appropriate quantitative or
qualitative acceptance criteria (limits) contained in applicable design documents. The VY
UFSAR, Section 1.9, states the VY Quality Assurance Program is in compliance with 10 CFR Part 50, Appendix B and ANSI N18.7-1976.
Contrary to the above, on and before September 20,1996, the licensee's surveillance
procedure, OP 4215, Rev. 6, " Main Station Battery Performance / Service Test," failed to
incorporate any appropriate acceptance criteria for the battery service test. The
acceptance criteria in the form of test shutdown voltage had no basis in any design
document. The battery test acceptance criteria failed to consider the minimum battery
terminal voltage used to determine the acceptable operation of safety-related de
equipment as documented in calculation VYC 1349, Rev. O, dated January 23,1995.
This is a Severity LevelIV violation.
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VERMONT YANKEE NUCLEAR POWER CORPORATION
United States Nuclear Regulatory Commission
December 20,1996
Page 2 of 3
Resconse:
1) Reason for the violation
Vermont Yankee does not contest this violation. The root cause of this violation was
deficient communication between Design Engineering and the Maintenance Department.
and within Design Engineering. The 125 VDC Voltage Drop Study, VYC-1349, was not
referenced in the maintenance test procedure nor were the minimum battery voltages
assumed in the study communicated to the Maintenance Department. Therefore, an
acpropnate acceptance enteria was not incorporated into the Main Station Battery
Performance / Service Test procedure (CP 4215). Insufficient guidance provided to the
preparer of the calculation, the need for enhanced procedural requirements and lack of
cwnership of VYC-1349 were identified as contributing causes.
2) Corrective steos that have been taken and the results achieved
a) A review of the Main Station Battery service test data recorded during the past refueling
outage was performed. As documented in the service test, the minimum voltage on
Batteries A and B was approximately 111 Vdc and 113 Vde, respectively. The 125
VDC Voltage Drop Study assumed a minimum voltage of 107 Vdc and 110 Vdc for
Batteries A and B, respectively. Therefore, the assumptions in VYC-1349 envelope the
test results and we conclude there are no operability concems associated with the Main
Station Batteries.
b) The 125 VDC Voltage Drop Study, VYC-1349, was evaluated in light of changes to the
Main Station Battery Sizing Calculation, VYC-298, and inspector comments. The
evaluation confirmed that sufficient voltage is available to operate DC loads from both
Batteries A and B.
c) The procedure which requires the ca!culation originator to review applicable FSAR,
Technical Specifications, Procedures (Cperating, EOPs, Surveillance, Maintenance).
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Technical Programs and Prints for impact has been distributed for review to all Design
Engineering staff to reinforce its requirements. This procedure was identified as a
failed barrier in the root cause analysis.
3) Corrective Steos that will be taken to avoid further violations
a) The 125 VDC Voltage Drop Study, VYC-1349, will be revised to be consistent with the
latest revision of the Main Station Battery Sizing Calculation, VYC-298. This is
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expected to be complete by April 30,1997.
b) Appropriate acceptance criteria for battery minimum voltages will be incorporated into
procedure OP 4215. This is expected to be complete by June 30,1997.
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VERMONT YANKEE NUCLEAR POWER CORPORATION
United Stat:s Nuclear Regulatory Commission
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December 20,1996
Page 3 of 3
c) Vermont Yankee will review and revise existing procedural requirements regarding
changes to and ownership of design casis calculations. Specifically, the requirements
for assessing the impact of calculaticn changes on pending changes, other
calculations, procedures and other design basis documents and the requirements for
communicating these changes will be reviewed. Training and implementation of the
revised procedural guidance is expected to be complete by April 30,1997.
d) Surveillance procedures associated with the batteries defined in Vermont Yankee
Technical Specifications will be reviewed against the applicable design bases
calculations to ensure consistency. This is expected to be complete by April 30,1997.
4) Date by which full comoliance will be achieved:
Vermont Yankee will have achieved full compliance once the main station battery
calculations and procedure OP 4215 are revised to include an acceptance criteria
consistent with the design basis of the DC system. These revisions are expected to be
completed by June 30,1997, well before the next use of procedure OP 4215 during the
Spring 1998 refueling outage.
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We trust that the information provided is acceptable. However, should you have any questions
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or desire any additionalinformation, please contact this office.
Sincerely,
VERMCNT YANKEE NUCLEAR POWER CORPOPATlCN
Dcnald A. Reid
Vice President, Operations
C: USNRC Region i Administrator--